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continuing failure to provide documents concerning their claimed
deductions other than a few documents that related to expenses
for 1995. The motion also pointed out petitioners’ failure to
submit a trial memorandum identifying witnesses as required by
the Court’s Standing Pre-Trial Order. Respondent’s motion was
set for hearing on January 28, 2002. When the cases were called
for trial on January 28, petitioners filed a Renewal of Motion to
Dismiss, repeating and expanding on scurrilous accusations
against respondent’s counsel and the Court and claiming that the
Court lacked jurisdiction because neither respondent’s counsel
nor the Court would provide copies of their oaths of office to
petitioners. Petitioners’ motion was denied. Respondent’s
motion in limine was granted.
The cases proceeded to trial on January 28. Petitioners
presented neither evidence nor argument that respondent’s
determination of specific items of income was erroneous. The
facts that were deemed stipulated connected petitioners to items
of income either by specific receipts or by bank deposits into
accounts under the control of petitioners. See Delaney v.
Commissioner, 743 F.2d 670 (9th Cir. 1984), affg. T.C. Memo.
1982-666; Tokarski v. Commissioner, 87 T.C. 74 (1986). The
testimony of Mr. Nordbrock and the documents presented for 1995
related to legal and other expenses of filing his personal
bankruptcy, repairs or improvements to petitioners’ home, travel
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